The
Centers for Medicare and Medicaid Services (CMS) recently updated its therapy question-and-answer document that clarifies several provisions
regarding the therapy functional reassessment requirement under the Medicare
Home Health Part A benefit. Medicare pays only for visits in which the therapy
reassessment is done in compliance with the Medicare regulations. Noncovered
therapy visits are not to be included in the counting of therapy visits for the
purpose of determining when certain required therapy reassessment visits need
to occur.

In
the Q&A, CMS clarifies that home health agencies and therapists should not
change the number of therapy visits a patient receives based on whether prior
visits were covered by Medicare, and patients should receive only the number of
therapy visits delineated in the plan of care. The Q&A also provides
detailed examples of when the therapy reassessment is missed or is not
compliant and its subsequent effect on the counting of Medicare-covered therapy
visits in single and multiple therapy cases.

CMS
requires that the patient's function must be initially assessed and
periodically reassessed by a qualified therapist of the corresponding
discipline for the type of therapy being provided (ie, physical therapy,
occupational therapy, or speech-language pathology services). When more than 1
therapy discipline is being provided, the corresponding qualified therapist
would perform the reassessment during the regularly scheduled visit associated
with that discipline that is scheduled to occur closest to the 13th and 19th
visit, but no later than the 13th and 19th visit.